Last Updated: April 19, 2021
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND WHAT WE DO WITH THE INFORMATION THAT WE COLLECT AS A RESULT OF YOUR ONLINE OR OFFLINE VISIT TO US.
This Policy is incorporated into and made a part of our Terms & Conditions, which may include an arbitration provision and class action waiver. Please note that we reserve the right to modify this Policy at any time. Material changes will be conspicuously posted on the Website or notice will otherwise be provided to you. All changes will be effective immediately upon posting to the Website unless otherwise stated.
To the extent, if you have any questions about or complaints concerning this Policy, please contact us at MGSparks@MGSparks.com and put in the subject line the reason for your inquiry.
This Policy is intended to provide adequate and consistent safeguards for the handling of certain “personal information,” “personal data,” or “personally identifiable information” as such terms are contemplated by Nevada state law and other state, federal, or foreign laws, if and to the extent applicable to The Nugget, such as the California Consumer Privacy Act, the General Data Protection Regulation as issued by the European Parliament and Council of the European Union, or other similar laws as they may be applicable (“Personal Data”).
If you are a California resident, additional information applicable to California residents is below in the Section titled “Your California Privacy Rights”.
A. THE TYPES OF INFORMATION WE COLLECT
Website & Services
You are not required to provide Personal Data to visit the Website. However, you must provide certain Personal Data to request information, make a reservation, or receive products or services from The Nugget. We may collect any content, record, or electronic communication of any kind that you elect to send to us as part of that process, so that we may provide you with such products and services, communicate with you regarding our products and services, and send you information and materials for marketing and other purposes, subject to applicable laws and the terms of this Policy.
To make a reservation, we require the following categories of information:
- Email Address. By providing your email address, you have the option to receive marketing emails. You have the choice to opt-out from marketing emails as further described below.
- Phone Number. If you elect to provide us a phone number during your reservation. You are not required to provide us a phone number to book your reservation or stay with us.
- Physical Mailing Address and Zip Code
- Payment Card Information. For further information on how we process payment cards, please see below
At check-in, we will require proof of your identity through a government-issued identification, such as a driver’s license or passport.
We may request a phone number from you at check-in, so that we can communicate with you to tell you when your room is ready and provide information about check-in and check-out. However, you are not required to provide us a phone number to stay with us.
Once you are on-site at our property, we may collect other Personal Data as part of (i) receiving and fulfilling reservation and information requests, (ii) your initial sign-on to access our guest wireless internet, (iii) purchasing products and services, (iv) registering for the Nugget Advantage Rewards program, (v) responding to communications from us (e.g., surveys, promotional offers, or reservation confirmations), and (vi) processing a casino credit application. These activities may require us to collect the following additional categories of Personal Data:
- Date of Birth. In order to join Nugget Advantage Rewards, we must verify your age, which requires us to collect your date of birth and maintain that Personal Data on file.
- Government Identification. In the event you sign up to join Nugget Advantage Rewards or otherwise visit the casino cage to purchase chips or collect winnings, we will scan your government-issued identification as required by government regulations (Military ID not currently accepted). We maintain the scanned information and store it in our gaming records. Your government-issued identification provides us with certain Personal Data, such as your photograph, name, address, gender, date of birth, government identification number, and any other data contained on your government-issued identification.
- IP MAC Addresses. In order to access our free WiFi services, we will collect your MAC address of each device that connects via WiFi and issue an IP address to that device. Use of WiFi is also subject to the Guest Wireless Network Terms and Conditions which you can view here.
- Casino Credit Application Information. In order to process a casino credit application, we will collect your date of birth, social security number, employer information and may also collect financial account information. We will process such information for purposes of confirming your credit eligibility and will maintain such information for purposes of maintaining and servicing any resulting credit with The Nugget. Government regulations also require us to maintain this information for compliance and regulatory purposes.
If you park your vehicle with us, we may collect information about your vehicle, including an image of the vehicle, the vehicle's make, model, and license plate number. This information may be collected manually (such as at check-in or by security). We use this information for safety, security, fraud prevention, and other similar purposes.
We may record calls for customer service, training, and other purposes, such as investigations and legal disputes. Call recordings may be stored for a minimum of 30 days but may be kept longer as reasonably necessary for security or other investigations, in the event of disputes or legal proceedings, or as otherwise required or permitted by applicable law.
When you contact us by any method, we collect and log the details of your request, concern or inquiry, and the contact information you provide, in order to respond to you. This information is logged in our internal systems maintained by us or by third-party providers on our behalf. For example, if you sign up for us to send you offers, we will use your email address to send you offers.
The Nugget employs video and audio surveillance technology both in the casino area and throughout the property. Video surveillance technology may also allow for the use of facial recognition technology. We may maintain surveillance recordings for at least seven (7) days and may maintain them for longer as necessary to meet our legal obligations and as contemplated by our policies.
Payment Card Information
Purchases of products or services must be made by credit or debit card. All credit and debit card information is provided directly to our third-party booking engines, travel agencies, and payment processors, which vary based on the products and services requested. If you elect to make a purchase, you will need to submit your card number, expiration date, security code, and billing address as well as other information as may be required by the applicable booking engine. In limited instances for group reservations, we may receive credit or debit card information for processing, which we may share with our third-party processors. Payment by credit or debit card is subject to the approval of the card issuer, and The Nugget will not be liable in any way if a card issuer refuses to accept a credit or debit card for any reason.
We use third-party vendors and their technologies to track how our Website visitors use our Website, including whether you complete a reservation, what other websites you visit to compare price, and the links and content you view on our Website. These vendors allow us to monitor your use of our Website live and record that usage session, which we use to help improve our Website.
Our Website may allow you to connect and share information with various social media platforms, such as Facebook, YouTube, OpenTable, Instagram, Twitter, and TripAdvisor. These features may require us to implement cookies, plug-ins, and/or APIs provided by such social media platforms to facilitate communications and features. We may share information that you provide us or that we may collect about your use of the Website with these platforms, and such information becomes subject to their privacy and data policies when we do so. We encourage you to visit the privacy policies of these platforms for further information:
- Facebook's Data Policy at https://www.facebook.com/full_data_use_policy
- Open Table at https://www.opentable.com/legal/privacy-policy
- TripAdvisor at https://tripadvisor.mediaroom.com/US-privacy-policy
In addition, by choosing to use any third-party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. We cannot control any policies or terms of such third-party platform. As a result, we cannot be responsible for any use of your information or content by a third-party platform, which you use at your own risk.
We may also use the advertising services and networks offered by these social media platforms, such as Facebook, YouTube, Instagram, and Twitter, to deliver ad content. We may share Personal Data with these social media platforms to allow such platforms to identify similar platform users that may be interested in our ad content. Use of these services requires the social media platform to implement cookies and/or pixels to deliver ads to you while online with such platforms.
We may also monitor our presence on social media ourselves or through third-party vendors, which means we may view your pictures or postings on social media that are from or relating to The Nugget. We may contact you from time to time through Personal Data that we may have or receive through the third-party social media platform or otherwise in order to request permission to use your content on our Website or for other purposes.
Behavioral and Targeted Advertising. We use third-party ad networks (called third-party ad servers or network advertisers, including Google and Facebook to deliver ads to you on our behalf. These third-party ad networks may place their cookies, web beacons or other technology on the Website or in your browser to collect non-Personal Data about you when you visit the Website (such as browser type, time and date, browsing or transaction activity, subject of advertisements clicked or scrolled over, or a platform-provided identifier during your visits to this Website and other websites) to enable those third-party ad networks to deliver advertisements to you on third-party websites and mobile applications for our products and services or those of third parties that are likely to be of interest to you. For example, Google uses the Doubleclick cookie to enable it and its partners to serve ads to you based on your visit to our Website and/or other websites on the internet.
You can also visit the websites http://www.networkadvertising.org or http://www.aboutads.info to change your consumer preferences with respect to certain online ads and to obtain further information about third-party ad networks and online behavioral advertising.
You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page and installing the Google Analytics browser add-on, currently made available by Google at https://tools.google.com/dlpage/gaoptout.
Google Analytics Advertising Features
We have also enabled the Google AdWords feature along with the following Google Analytics Advertising Features: Google Display Network Impression Reporting, Remarketing with Google Analytics, and Google Analytics Demographics and Interest Reporting. The Google Display Network Impression Reporting uses the Google Analytics cookie to track our ad impressions and your interactions with those impressions, including the effectiveness of those ads, which generates reports for us to help us analyze our advertisements. Remarketing with Google Analytics uses the Google Analytics cookie to serve advertisements to you across the internet based on your visit to our Website. Google Analytics Demographics and Interest Reporting uses a third-party cookie to collect information about our Website traffic by tracking users across websites and across time, which generates a report for us to better understand our Website users.
We may initiate surveys from time to time, using a third-party survey provider. The survey provider collects and processes your survey responses on our behalf and provides us the information in response to the surveys. We use this survey data to help improve our services and our Website.
We also collect information that, in and of itself, cannot be used to specifically identify you, such as the characteristics of the device and software that you use to access the Website. This information includes without limitation internet browser type, other characteristics of your device and software, domain names of your Internet Service Provider (ISP), your approximate geographic location, a record of your usage of the Website, the time of your usage and aggregated personal data that cannot be used to specifically identify you. IP addresses are not used to track a user’s session, and we do not link IP addresses to any Personal Data. IP addresses help us determine your approximate geographic location and how often different areas of the Website are visited. We will use this information to monitor and prevent fraud, diagnose problems, and anonymously estimate demographic information. Such information, which is collected passively using various technologies, cannot in and of itself be used to specifically identify you. We also collect this type of data (including without limitation information of the types set forth above) from third parties. The information we collect from third parties may be combined with the information we collect from you. Our Website provider may collect information about your visits to the Website and other websites, such as your user settings.
B. HOW WE USE AND SHARE INFORMATION
We may use any Personal Data or other information that you voluntarily provide to us to provide you with information, products, or services that you may request from us. We do not sell, rent, or loan any of your Personal Data to any third party for monetary consideration.
We may share information with those persons and third parties specifically involved in processing your purchase or receipt of our products or services, accommodating your stay and activities while on our property, or other activities involving the provision, maintenance, and improvement of the Website and other products and services. We will not share the information that is collected to others in ways that differ from what is disclosed in this Policy.
We will use and share your information if we believe doing so is necessary to accommodate your stay and activities while on our property and otherwise to operate the Website as further set forth below. We use your information to customize your browsing experience, display custom content to you, communicate with you, and otherwise respond to your questions and suggestions regarding the Website as may be permitted by applicable law. The Nugget may also use your Personal Data to send you promotional communications and information about The Nugget that we think may be of interest to you.
Your permission to use the Personal Data we collect from you via your interactions with us in other ways may be implied from the nature of the service requested or transaction undertaken. For example, your permission will be deemed given for communications from us that are necessary to fulfill transactions and services that you request, such as ongoing communications regarding the status of a reservation or maintenance of an account with us.
We will send you emails regarding your transactions with us. We will also send you marketing emails if you provide us your email address. You may unsubscribe from marketing emails from The Nugget by clicking on the “unsubscribe” links in those emails. Please note that if The Nugget has shared your information with third parties as permitted by this Policy, opting out or unsubscribing from marketing messages from The Nugget will apply to marketing messages coming from The Nugget only, and not to marketing messages coming from such third parties. To opt-out of messages from third parties, please contact those third parties directly.
We reserve the right to share your information collected from the Website with third parties to the extent permitted by applicable law, or if in our sole discretion, it is reasonable to do so, including in the event of a subpoena or law enforcement request, security issue or to protect our rights or the rights of a third party. We may also disclose information that is necessary to identify, contact, or bring legal action in the event of a violation of our contracts, policies, or procedures.
Sharing Information with Our Suppliers
We may share information with our suppliers, marketing suppliers, reservation system provider, advertising agencies, email suppliers, booking engines, and other suppliers as necessary to provide the Website (including all of the Website’s features) and our products and services to you. We require those suppliers to comply with all applicable data privacy laws and regulations. These suppliers are authorized to use your Personal Data only as necessary to provide the applicable services to us.
We may aggregate your Personal Data, either alone or with other data, to create anonymous “aggregate data” regarding the users of our Website. Aggregate data is information that describes the habits, usage patterns, or demographics of users as a group but does not reveal the identity of particular users. This data will not identify you but will be used by The Nugget internally as statistical information to determine such things as user demographics and usage patterns of our Website. We may use aggregate data to understand the needs of our community of users, to determine what kinds of programs and services we can help provide, and to improve and enrich our products, services, marketing, and Website content.
Cookies and Other Tracking Technologies
C. SECURITY MEASURES WE TAKE TO PROTECT YOUR PERSONAL INFORMATION
We have implemented commercially available technical, administrative, and physical security measures in an effort to safeguard the privacy of your Personal Data from unauthorized access or improper use. We limit regular access to Personal Data to our employees, and third parties whom we believe need to have access to such information for The Nugget to respond to your requests and provide you with the information, products, or services you request from us as well as those employees and third parties whom we use to provide us with services.
From time to time, The Nugget will review our security procedures in order to consider appropriate new technology and methods to enhance our security procedures as new technology becomes available. However, you acknowledge and agree that despite these efforts, no security measures are perfect or impenetrable, and your Personal Data may still be accessed and used by others without authorization in the event of a security breach.
D. YOUR RIGHTS
If your request to review or update your Personal Data is denied, you have the right to be informed about the reasons for denial.
You may request information as to the nature of the Personal Data stored or processed about you by The Nugget and may request amendments to that Personal Data at Player Services. If any information is inaccurate or incomplete, you may request that the data be amended. It is your responsibility to provide us with accurate Personal Data about yourself and to inform us of any changes. (e.g., new home address or change of name).
E. CALIFORNIA PRIVACY RIGHTS
Subject to certain limitations, if you are a California resident you may make the following requests with regard to your Personal Data. Instructions on making these requests is below. Please note that California law allows California residents to make the following requests, but applicable law may not require, permit or authorize us to honor all requests.
Right to Know. You have a right to request information on the following information: (a) the categories of Personal Data we collected about you in the prior 12-month period, (b) the categories of sources from which the Personal Data was collected, (c) the business or commercial purpose for which we collected your Personal Data, (d) the categories of Personal Data we disclosed in the prior 12-month period, and (e) the categories of third parties with whom we shared your Personal Data.
Right to Access. You have a right to request that we disclose to you the specific pieces of Personal Data that we have collected about you in the prior 12-month period.
Right to Deletion. You have a right to request that we delete Personal Data we collected about you.
Right to Opt-Out of the Sale. California law provides you the right to request to opt out of the sale of Personal Data. However, at this time we do not “sell” Personal Data as contemplated by applicable laws.
Non-discrimination. You have a right to submit the above requests and we will not discriminate against you for exercising these rights.
How to Exercise Your Rights. To exercise your rights described in this Policy, you may submit your request to us by contacting us at any of the following:
Website: Our “Contact Us” webform contains a comments section allowing you to indicate the nature of your request and provide your preferred contact information.
Email: If you submit your request via email, please identify in the subject line the type of request that you are submitting (Request to Access Data, Request to Know Categories Collected/Shared, Request to Delete) and provide your name. The email address of the request will be used as contact information for you.
Who May Exercise Your Rights. You may make a request to exercise the above rights on behalf of yourself or on behalf of a child if you are a parent or legal guardian of the child. In addition, you may authorize an agent to exercise your rights on your behalf, if you provide the agent with written signed permission. Any legal entity acting as your agent must be registered with the Secretary of State to do business in the State of California. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent, unless the agent holds a lawful Power of Attorney under California probate laws, in which case we will require evidence of such Power of Attorney.
Verification of Your Request. Once we receive your request, we will contact you to confirm receipt of your request. In addition, we may request that you provide us with additional information to allow us to verify your identity, the identity of the person that is the subject to of the Personal Data you have requested (if other than you), and the authenticity of your request. The information we may request may vary depending on the Personal Data we already have in our systems.
Certain types of requests, such as a request to access, may require additional verification to ensure you are who you say you are as we are subject to higher standards of authentication with respect to such requests.
If you have used an agent to make your request, we will also need to verify the identity of the agent. If you use an authorized agent, verification of your request may require you, or your agent if applicable, to sign an affidavit verifying identity.
We may deny your request as permitted or as required by law, if we are unable to verify your identity or the authenticity of the request, or if an agent makes the request on your behalf, if we are unable to verify their identity or proof of their authorization.
CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
Categories of Personal Data. Below are lists of Personal Data required by California law identifying the Personal Data collected, where they are sourced, why they are collected, and if we disclose such Personal Data, the categories of service providers or other third parties to whom we disclose them:
|Category of Personal Data||Source||Purpose Collected||Discloused for a Business Purpose||Categories of Entities We Disclose To|
|Identifiers||Directly from you onsite, via our Website and other online services. Indirectly from travel agents and other booking service providers||Providing you the service, product or communication requested and documenting the request. Contacting you regarding our services or products. Marketing our services and products to you. Safety, security, and fraud detection. Legal and regulatory requirements and best practices.||Yes||Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services.|
|Personal Information categories under California Customer Records statute (Cal. Civ. Code 1798.80(e))||Directly from you onsite, via our Website and other online services. Indirectly from travel agents and other booking service providers||Providing you the service, product or communication requested and documenting the request. Contacting you regarding our services or products. Marketing our services and products to you. Safety, security, and fraud detection. Legal and regulatory requirements and best practices.||Yes||Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services.|
|Commercial information||Directly from you via the transactions you conduct onsite and online.||Processing your payments. Processing credit applications. Records of your activities onsite, on our Website and other online services.||Yes||Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services.|
|Biometrics||Directly from you while onsite via security surveillance systems.||Security and legal investigations.||Yes||Service providers involved in the provision and maintenance of our security and surveillance systems.|
|Internet||Directly from you, your computer or other device. Indirectly from our service providers.||Providing you the service, product or communication requested and documenting the request. Displaying and customizing content on our Website and other online services. Improving our Website and other online services. Marketing to you on other Websites and apps.||Yes||Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services. Third party social media platforms. Third party advertising networks and analytics providers. Third party survey providers.|
|Geolocation (approximate only)||Directly from you via IP address.||Tracking use of our website and other online services.||Yes|
|Professional or employment-related||Directly from you via IP address.||Processing credit applications.||Yes||Service providers involved in processing or providing our products and services.|
Although the categories of information above are collected for the designated purposes, Personal Data may be otherwise used for the purposes set forth in this Policy to the extent such use is consistent with the purpose for which it is collected.
To our knowledge we have not sold any Personal Data of an individual under 16 years of age. Based on current California laws, to our knowledge, we have not sold any Personal Data in the last 12 months.
The below companies may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.
F. OBLIGATIONS TO DATA PROTECTION AUTHORITIES (“DPAS”)
We will respond diligently and appropriately to requests from DPAs about this Policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide the DPAs with the names and contact details of the individuals designated to handle this process. With regard to transfers of Personal Data, we will (i) cooperate with inquiries from the DPA responsible for the entity exporting the data and (ii) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with the DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.
G. THIRD-PARTY WEBSITES
The Website may link to, or be linked to, websites not maintained or controlled by The Nugget. Such links are provided as a convenience, and The Nugget is not responsible for the content or accuracy of, and does not warrant or endorse, any third-party website. The Nugget is not responsible for the privacy policies or practices of any third parties or third-party websites, including any websites linked to or from the Website. To the extent that you disclose Personal Data to any such third parties, different rules may apply to the use and disclosure of such information. We encourage you to review the privacy policies of third-party websites before disclosing your Personal Data to them.
H. INFORMATION FROM CHILDREN
We do not knowingly collect Personal Data from children under the age of 13. If you are the parent or guardian of a person under the age of 13 and believe that such person has provided The Nugget with Personal Data please visit Player Services.
I. CONSENT TO THIS POLICY AND CONTACT INFORMATION